Privacy Policy for Clients

1.Processing of personal and sensitive data

For the purpose of an EFT session/ VIP day I will process the following personal data provided by you (referred to as „data subject“), namely:

your name, address, email address, phone number and eventually your tax identification number, company registration number, as well as your date of birth (referred to as „personal data“)

As far as you provide access of these data, I will additionally process the following special categories of personal data, namely sensitive data:
your current health state or your current medical diagnosis, health disorders or your medication intake as well as confidential data of your private and intimate life, your religious confession, political or world view or your professional life (referred to as „sensitive data“).

2. Responsible (referred to as „controller“)

3.Purposes for processing your personal and sensitive data and lawfulness

Your personal data will be processed for the following purposes:

Personal data will be processed and transferred within the scope of conducting EFT sessions with clients and participants , including text documents (e.g. minutes, correspondence) on this matter created and stored with the aid of computer technology.

The processing is carried out on the basis of Article 6 (1) lit h GDPR.

Sensitive data will be processed solely for purposes of your session and/or VIP day. The processing is carried out on the basis of Article 9 (2) lit h GDPR.

4.Recipient of personal data

The data subject’s personal data will be transferred to the recipients listed below:

5. Retention period of personal and sensitive data

Personal data will be stored for a period of 7 years.
Sensitive data will be stored for a period of 3 years.

6. Necessity of providing personal and sensitive data

The data subject is not obliged to provide personal data. However, providing personal data as listed below, namely his or her name, address and email address, is necessary for concluding a contract with the controller.

The data subject is not obliged to provide his or her sensitive data.

7.Right to access information

The data subject shall have the right to obtain from the controller confirmation as to whether or not personal and sensitive data concerning him or her are being processed, and, where that is the case, access to the personal and sensitive data and the following information:

intended purposes of the processing

the categories of personal and sensitive data concerned

the recipients or categories of recipients, to whom personal data have been or will be disclosed; in particular recipients in third countries or international organisations

where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;

the existence of the right to request from the controller rectification or erasure of personal and sensitive data or restriction of processing of personal data concerning the data subject or to object to such processing;

Right to lodge a complaint with a supervisory authority;The controller shall provide a copy of the personal data undergoing processing. For any further copies requested by the data subject, the controller may charge a reasonable fee based on administrative costs. Where the data subject makes the request by electronic means, and unless otherwise requested by the data subject, the information shall be provided in a commonly used electronic form.

8. Right to rectification

The data subject shall have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

9. Right to erasure/ „right to be forgotten“

You have the right to demand the immediate erasure of all your personal and sensitive data from the controller ; the controller is obliged to erase all personal and sensitive data if one of the following reasons applies: :

The personal or sensitive data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.

You object to the processing pursuant to Article 21 (1) or (2) GDPR and in case of objection there are no overriding legitimate grounds for the processing pursuant to Article 21 (1) GDPR.

The personal or sensitive data have been unlawfully processed..

The personal or sensitive data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.Where the controller has made the personal data public and is obliged to erase the personal data, the controller shall take reasonable steps to inform controllers which are processing the personal data that the data subject has requested the erasure by such controllers of those personal data.

10. Right to restriction of processing

The data subject shall have the right to obtain from the controller restriction of processing where one of the following applies:

The accuracy of the personal or sensitive data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal or sensitive data.li>

The processing is unlawful and the data subject opposes the erasure of the personal or sensitive data and requests the restriction of their use instead;

The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims;

The data subject has objected to processing pursuant to Article 21(1) GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject. A data subject who has obtained restriction of processing shall be informed by the controller before the restriction of processing is lifted.

The controller shall communicate any rectification or erasure of personal data or restriction of processing carried out to each recipient to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort. The controller shall inform the data subject about those recipients if the data subject requests it.

12. Right to data portability

The data subject shall have the right to receive the personal or sensitive data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal or sensitive data have been provided, where:

the processing is based on a contract pursuant to point (b) of Article 6(1);

the processing is carried out by automated means.li>

In exercising his or her right to data portability, the data subject shall have the right to have the personal or sensitive data transmitted directly from one controller to another, where technically feasible.
The exercise of the right to data portability shall be without prejudice to the right to erasure.

13. Right to object

The data subject shall have the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her which is based on point (e) or (f) of Article 6(1) GDPR.

The controller shall no longer process the personal data unless the controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.

Where personal data are processed for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing, which includes profiling to the extent that it is related to such direct marketing.
Where the data subject objects to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.

14. Right to lodge a complaint with a supervisory authority

Without prejudice to any other administrative or judicial remedy, every data subject shall have the right to lodge a complaint with a supervisory authority, in particular in the Member State of his or her habitual residence, place of work or place of the alleged infringement if the data subject considers that the processing of personal or sensitive data relating to him or her infringes this Regulation or §1 or Article 2 (1) of the GDPR 2018. In Austria the High Authority for data protection shall be responsible.

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